Treat recruiting, wages, and training as operating costs of the enterprise, planned and funded, and keep them separate from immigration-preparation expenses. Whether a particular professional fee forms part of qualifying investment depends on what it was for and how it was actually treated, so review each item rather than assuming a single rule.
Separate the business budget from the case budget
Build one column for the enterprise—purchase price, inventory, equipment, premises, staffing reserve—and another for preparing and presenting the case. Confirm current government charges at the time each step is taken rather than relying on a figure quoted earlier. Ask any adviser to itemize what their scope covers, including responses to later questions. No amount of spending secures approval or a particular return on the investment.
Substantiality is measured against the total cost of establishing this particular enterprise, not against a fixed threshold. E-2 has no universal minimum, but the total qualifying capital must be substantial relative to the enterprise and irrevocably committed at risk. Salaries paid from trading revenue, monthly rent and instalments on a leased vehicle are the cost of running the business and are not the investment, however large the total becomes over a year. Compare the total with the cost of the specific enterprise to assess substantiality, then show that the operation is real and not marginal.